AI translation of the German original. Legal references and sources remain those of the original document. German version.

¶ Criticism, Counter-Arguments and Interests

Language versions: Deutsch · Français · Italiano · English · Rumantsch

¶ Data Protection Organisations

Digitale Gesellschaft demands active self-determination and encryption with keys under the control of the data subjects. Its position paper differentiates: the storage location is less decisive than key control; even centralised storage could be compatible with appropriate encryption. The organisation calls for advisory onboarding before the dossier is filled. Position of 16 April 2026

The Pirate Party demands opt-in, patient-controlled encryption, open independent code review and targeted data releases. It is examining a referendum. Its statement of 14 September is a political position; it does not replace a security audit of the future system. Party statement

Counter-argument or later status: The National Council has added statutory security and permission requirements. Whether these practically address the criticism of key control and default settings continues to depend on the architecture. Decision Amendments · Security

¶ Medical Profession and Hospitals

The FMH supports the strategic reorientation but warns against isolated legislation for the dossier and the health data space. H+ supports, according to the session review of 2 October 2026, the thrust of the National Council's position and demands a binding transition, clear governance and secured financing. A blanket current "stop order from all doctors and hospitals" does not do justice to these positions. FMH Current H+ position

¶ Health Insurers

prio.swiss supports the mandatory connection requirement and opt-out. The association additionally demands that medical trustees with consent be given access to necessary documents. This is a demand for specific tasks, not a claim to a generally open dossier. Association paper

The requested expansion of the definition of terms was not adopted in the National Council decision. The existing tasks of the medical trustee under health insurance law must be considered separately. Art. 2 and 11 FDPIC: Medical trustee and medical confidentiality

¶ Making Interests Visible

Editorial assessment: Authorities are responsible for the project, associations represent their members, and technology providers may have an interest in future contracts. A source can be technically relevant and at the same time interest-driven. This wiki therefore names the publisher, document type and date; criticism is not automatically treated as a proven risk, and a promise of benefits is not treated as an established outcome.

Further: Costs · Implementation